Thread Subject: Cognitive

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From: Baquis David
Date: Wed, Nov 08 2006 4:50 PM

There was a discussion about standards for cognitive disability during today's plenary meeting and I want to add a few comments to the mix:



First, I did not hear anyone remind the Committee that this is addressed in the 255 guidelines for designing telecom products for people with cognitive disabilities. I am not saying those guidelines are sufficient. However, I would not want you leaving with the impression that we currently have nothing on the matter. It is important to regularly keep 255 in mind. To respond to a question from Gregg today, we are envisioning a single document at the end of the rulemaking process that folds 255 and 508 into one. The goal is not to have two separate documents like we have now and just make them consistent.



See: http://www.access-board.gov/telecomm/rule.htm

§ 1193.41 (i) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.



Here is what the advisory notes section said about that provision:

Paragraph (i)

Operable with Limited Cognitive Skills

1. Many individuals have reduced cognitive abilities, including reduced memory, sequence tracking, and reading skills. This does not necessarily prevent these persons from using a telecommunications product or feature.

2. The following strategies are extensions of techniques for making products easier for everyone to learn and use:

a. Use standard colors and shapes and group similar functions together. On products which have some controls that are used by everyone and other controls which would only be used by advanced users, it is generally good practice to separate the two, putting the more advanced features behind a door or under a separate menu item.

b. Products which read the contents of the display aloud, or controls which announce their settings, are easier for individuals who have difficulty reading.

c. Design products that are self-adjusting to eliminate additional controls which must be learned, and reduce the visual clutter.

d. On products which have sign-in procedures, allow user settings to be associated with them when they sign in or insert their identification card. The system can then autoconfigure to them. Some new "smart cards" are being designed with user preferences encoded on the card.

e. Where a complex series of steps is required, provide cuing to help lead the person through the process. It is also helpful to provide an "undo" or back up function, so that any mistakes can be easily corrected. Most people will find this function helpful.

f. Where functions are not reversible, request some type of confirmation from the user before proceeding. On labels and instructions, it is helpful to use short and simple phrases or sentences. Avoid abbreviations wherever possible. Eliminate the need to respond within a certain time or to read text within a certain time.



Second, Section 508 actually does include some provisions that benefit people with cogntive disabilities. Even though 508 does not "overtly" address cognitive in Subpart C, it would not be accurate to assume that nothing we currently provide is directly helpful to people with cognitive disabilties. I will give you two examples: the timed response provision and the text equivalents provision. Receiving a time out warning and a means of extending time can help people who need more time for whatever reason: cognitive, vision, dexterity, etc. And the text equivalent provision can help people with learning disabilities that use specialized screen reader assistive software which allows them to read and hear at the same time.



3. Third, the Access Board helped plan a conference earlier this year on Technology For Improving Cognitive Function. See: http://icdr.us/cognitive/. The Access Board even helped lead a breakout group on recommendations related to research on cognitive technology standards. Maybe you can find a speaker or expert participant from that conference to help inform you. This was coordinated and hosted by the Interagency Committee on Disability Research of which we are a member. If you are not already aware, ICDR welcomes recommendations from anyone on future directions for federal research in disability and rehabilitation issues. ICDR helps set the future federal research agenda on disability and rehab.



David Baquis

Accessibility Specialist

U.S. Access Board

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Washington, DC 20004

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